ML20100R269

Statement of Matl Facts as to Which There Is No Genuine Issue Re Eddleman Contention 57-C-13 Concerning Offsite Emergency Planning

ML20100R269
Person / Time
Site:	Harris
Issue date:	12/12/1984
From:	Hollar D CAROLINA POWER & LIGHT CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20100R257	List: ML20100R253 ML20100R269 ML20100R277
References
OL, NUDOCS 8412170366
Download: ML20100R269 (3)

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h),hember 12, l'984 s UNITED STATES OF AMERICAd4 ~ DEC 14 pll gg - -

NUCLEAR REGULATORY COMMISSION

. BE_EFORE THE ATOMIC SAFETY AND LICENhbkh[bfAW BRAN'Ch

In the Matter of ) -

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. CAROLINA POWER & LIGHT COMPANY' -) '

Docket No. 50-400 OL-AND NORTH CAROLINA EASTERN '

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MUNICIPAL POWER AGENCY )

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l(Shearon Harris Nuclear Power Plant)

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APPLICANTS' STATEMENT OF MATERIAL PACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON EDDLEMAN CONTENTION 57-C-13 c.

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Pursuant to 10 C.F.R. 5 2.749(a), Applicants state, in support of their Motion for s -;

. Summary Disposition of Eddleman Contention 57-C-13 in this proceeding, that there is no genuine issue to be heard with respect to the following material facts:-

._ .l. Eddleman Contention 57-C-13 claims that the- areas with the highest protection factor (PF)-of each hospital and nursing- home within the Harris plume

- exposure' pathway EPZ should be determined . in advance (before the emergency

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preparedness exercise) to comply with the requirements of 10 C.F.R. S 50.47(a)(1).

. 2. In response .to the concerns raised by-this Contention, a surv7y of each nursing home, hospital and family care facility within the EPZ has been undertaken to i determine the best PF area of each facility. Pugh Affidavit,15.~

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3. Based on information about the nature of radiological releases, criteria for determining the best PF areas were developed to complete the survey. Pugh Affidavit, il 13-4.

4. The survey procedure involved interviewing the owners or administrators of L

each facility and inspecting those structural features which determine the effectiveness 8412170366 841212 gDRADOCK 05000400 J PDR C

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of the structure in reducing radiological doses. The survey was conducted by shelter,

. analysts certified by the Federal Emergency Management Agency. Pugh Affidavit,

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5. As a result of this survey, the best protection factor of each faellity has b6en identified whenever possible. Where a significantly better PF area was not readily Identifiable, guidance on steps that can be taken to minimize the dose received by persons in the facility are contained in the survey results. Pugh Affidavit,118-9.

6. In order to assist in identifying areas where patients might be moved in an accid'e nt situation, the owners or administrators of all facilities were orally apprised at the time of the survey of which areas within their facility provide the best protection from a radiation release. Pugh' Affidavit,112.

7.' A followup letter will be sent to all owners or administrators to tell them of

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the survey results and recommend a preferred sheltering location within their facility.

The Division of Emergency Management will also retain this information for reference at the time an accident may occur. Pugh Affidavit,112.

' The actions taken are adequate to identify the best PF areas of each hospital,-

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nursing home and family care facility within the Harris plume EPZ and, therefore, satisfy the requirements of 10 C.F.R. S 50.47(aXI).

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This 12th day of December,1984.

d.

Submitted by:

Dale E. Hollar, Esq.

Associate General Counsel Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-8161 7 2-w ,, -, ,.- v-"--w- T e t-e*yf erv**-w w'* ws rw #- v 'g e*w e"-9 7 9 ~wr-ve

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' Attorneys for Applicants:

Thomas A. Baxter, P.C.

Delissa A. Ridgway, Esq.

- Shaw, Pittman,' Potts & Trowbridge

.1800 M Street, N.W. >

' Washington,-D.C. 20036 (202) 822-1000.

Richard E. Jones, Esq.

Samantha Francis Flynn, Esq..

H4 Hill Carrow, Esq. - -

Carolina Power & Light Company.

Post Office Box 1551

,- - Raleigh, North Carolina 27602 =

~ (919)136-6517 O

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